Giveaways, gifts, entertainment and hospitality

SPIC Brasil believes that the exchange of gifts is a way to honor and strengthen relationships with colleagues and partners. However, giving gifts to partners and colleagues requires some attention. This does not mean that this kindness cannot be done, on the contrary, it must be in accordance with good business practices, which requires some additional care.

It is not correct to accept gifts from third parties who are participating in competitions. If the gift has already been delivered, it can be returned or, if this is not possible, the item will be donated to charities located in communities where we operate or will receive another destination, in accordance with the deliberation of the Ethics and Integrity Committee.

Definitions:

• Giveaways are marketing objects or materials, with low unit added value, personalized with a logo, have impersonal characteristics and are used to promote the third party’s brand, for example: pens, mugs, notebooks, mouse pads.
• Gifts are materials with greater added value, used in customer relationship actions, and may or may not have a logo, such as wine bottles, breakfast baskets, Panettones, etc.
• Entertainment are activities or events with the aim of entertaining, distracting or amuse. Common types of entertainment are leisure travel, cultural events (such as theatre, opera and concerts) and sporting events (such as football, tennis and volleyball).
• Hospitalities are acts performed in a professional context, welcoming, hosting and feeding people temporarily displaced from their work environment. They can be classified as such, primarily, meals, drinks, accommodation, travel, tours and transport.

The Code of Conduct and Ethics, in turn, prohibits the offer or receipt of gifts, gifts, entertainment or hospitality, on a regular basis, with a value exceeding R$ 300.00 (three hundred reais) per person, in a period of 12 (twelve) months, or any amount, if the counterparty is participating in a competitive process in any of the companies of the SPIC Brasil group.

If the employee notices something inconsistent in accordance with the rules established in the Giveaways, Gifts, Entertainment and Hospitality Policy or any other internal regulations, reporting in the SPIC BRASIL’s ETHICS CHANNEL is recommended.

We would like to emphasize that, when reporting, the employee contributes to the continuous improvement of the Company’s processes.

Suppliers and partners also have access to the Code of Ethics and Conduct for third parties, available at the link:

Code of Conduct and Ethics for Third Parties